Jeffrey A. Singer, Terence Kealey, and Bautista Vivanco
The MAHA Report, released by Secretary of Health and Human Services (HHS) Robert F. Kennedy, Jr. in late May amid much fanfare, was produced by the Make America Healthy Again Commission, which was established under President Trump’s executive order issued on February 13, 2025. This order required the commission to develop a “Make Our Children Healthy Again Strategy” within 100 days of the order’s date.
Again? Make America Healthy Again? It’s an odd slogan in a country that has long ranked last in health outcomes among its peers. If the United States were merged with Canada, Greenland, and Panama, our average health statistics would improve overnight. Consider, for example, the pellagra epidemic that began at the start of the 20th century and lasted into the 1940s.
Between 1900 and 1940, some three million US citizens developed pellagra, of whom 100,000 died—this when pellagra was rare outside the home of the brave and the land of the free. Pellagra is a debilitating disease known for the four Ds (diarrhea, dermatitis, dementia, and death). Pellagra’s prevalence was disproportionately high in the Jim Crow South, where systemic racial injustice shaped both diet and disease.
Its cause was discovered by an immigrant, Dr. Joseph Goldberger, a graduate of New York University. While working for the precursor body of the National Institutes of Health (NIH), he demonstrated that pellagra was a disease of malnutrition. Pellagra is a vitamin deficiency that occurs in people who eat little but industrially milled corn. Indeed, it’s hard to acquire pellagra because the key vitamin is found in practically all foods except industrially milled corn.
Dr Goldberger made his key observations at the Georgia State Sanatorium, a mental asylum where pellagra was rampant. For his experiment, Goldberger fed a group of patients a balanced diet of, you know, meat and vegetables and stuff. Whereupon their pellagra was cured. Once the experiment was complete, the fiscally responsible burghers of the peach state promptly returned the subjects to their former diet of industrially milled corn and industrially milled corn alone. And their pellagra promptly returned.
The president’s executive order gave the Commission 100 days to develop a strategy. One hundred days! Why so long? Surely, a policy analysis on such a complex and nuanced issue with myriad complicating factors could be produced over a weekend. Particularly as, of the 14 MAHA commissioners, only two (Dr. Jay Bhattacharya and Dr. Marty Makary) have medical or scientific backgrounds. The rest are mostly lawyers, all are political appointees, and everybody knows that a group of politically appointed lawyers is just the ticket for investigating matters of medical science.
This does not imply that Commission members without a medical or scientific background cannot ask critical questions or offer valuable insights that might not emerge from within the medical community’s bubble. We believe the scientific community should not be viewed as a priesthood, a lesson we learned the hard way during the COVID-19 pandemic. However, we would prefer a Commission with fewer political appointees and more representation from individuals in the private sector who have a background in medical and scientific research. Ideally, none should be political appointees; however, they should all report their findings to the Secretary of HHS (another lawyer with no medical background).
Happily, the Commission already knows why US children are uniquely unhealthy. By a strange coincidence, these reasons happen to be the ones the Commission’s chairman, one Robert F. Kennedy Jr., has been trumpeting for years. They include US children’s consumption of ultra-processed food, their use of smartphones, the chemicals in their environment, their lack of exercise, their stress levels, their lack of sleep, and their overmedicalization, especially with those pesky vaccines.
Oddly, however, the data in the report bears little relationship to its conclusions. For example, the first sentence of the introduction reads: “Despite outspending peer nations by more than double per capita on healthcare, the United States ranks last in life expectancy among high-income countries—and suffers higher rates of obesity, heart disease, and diabetes.” But the graph the Commission supplies shows that, dating back to 1970, the US has always ranked last in life expectancy among comparator nations. Were Americans back in 1970 dying sooner than Canadians, Europeans, or the Japanese because of ultra-processed food, smartphones, chemicals, a lack of exercise, stress levels, a lack of sleep, and overmedicalization? Probably not.
The reason for the US’s poor medical performance lies in the culture that gave us pellagra, which includes the nation’s unusually high level of social inequality for a rich country, regulatory barriers to access to health care, its extraordinarily high levels of road traffic deaths (which are today seven times higher in the US than in Sweden, say), its unusually high levels of gun deaths (which are today 340 times higher in the US than the UK for example), its extraordinarily high incarceration rate (prisoners may die from natural causes 20 years earlier than the general population), and other obvious social factors—which is why Mississippi has a life expectancy 8 years lower than states like Hawaii or Washington.
Defining Terms
While worthy of investigation, Kennedy and his commission play fast and loose with the terminology and the data. Most nutritional researchers (including those cited in the MAHA Report) use the Nova system, developed at the University of Sāo Paulo, Brazil, to classify foods: unprocessed foods are naturally occurring foods with no added salt, sugar, oils, or fats; processed foods have been milled or cooked with added sugar, salt, or spices to enhance their flavor; ultra-processed foods are mass-produced using multiple additives in addition to sugar, salt, and spices to enhance the food’s flavor and appearance and prolong its shelf life.
Kennedy and the Commission suspect that ultra-processed foods are largely responsible for the “epidemic” of chronic illness. But they paint with a broad brush. Which ingredients in which ultra-processed foods cause which chronic illnesses?
Some recent studies link specific ingredients in ultra-processed foods to certain illnesses, although this field of study is still in its early stages. While ultra-processed foods are often discussed as a category, researchers are beginning to isolate specific ingredients or additives that may contribute to health risks. However, many findings derive from animal studies or observational human studies, which cannot establish causality. Additionally, different ingredients appear in varying amounts across different ultra-processed foods. The dosage, frequency, and individual susceptibility vary significantly. It’s often challenging to isolate the effects of individual ingredients from the matrix of ultra-processed foods, which typically contain multiple risk factors (e.g., salt, fat, sugar, additives).
Studies indicate that even experts find it challenging to classify foods according to the Nova system consistently. For instance, various evaluators have classified plain yogurt as minimally processed, processed, or ultra-processed because they use unclear criteria. The Nova classification categorizes many fortified or enriched foods as ultra-processed, even baby formula.
Implementing policies based on Nova could limit access for low-income individuals and families to some of the few affordable options for these nutrients. Evidence shows that excluding ultra-processed foods from diets may lead to lower intakes of essential nutrients that are particularly concerning for at-risk groups, including women of childbearing age. Foods containing whole grains are categorized as ultra-processed (such as breakfast cereals and enriched bread), even though consuming them is associated with a reduced risk of cardiometabolic issues. These whole grain foods often contain niacin, which helps prevent pellagra.
Then there’s the matter of defining “chronic illness.” According to various health agencies and researchers, the number of recognized chronic conditions ranges from about 20 to 40 commonly tracked chronic illnesses in public health reporting (e.g., by the Centers for Disease Control and Prevention or the Center for Medicare and Medicaid Services) to potentially over 3,000 if one examines the entire International Classification of Diseases (ICD-10) set and applies a broad definition of chronicity (as Kennedy alludes to).
One chronic condition receiving a great deal of attention is childhood obesity. Yet a graph on page 10 of the MAHA Report, citing World Health Organization 2025 data, reveals that childhood obesity in the US peaked in 2005 and has remained steady or slightly declined over the past 20 years. Meanwhile, childhood obesity in most other countries has been increasing.
The MAHA Report presumes that America’s diet is behind the “epidemic” of chronic diseases. However, without consistent terminology and quality research, it proceeds based on vague assumptions.
The Commission regards Dr. Jonathan Haidt’s research suggesting that smartphones have harmed children and adolescents, particularly girls, as axiomatic. However, many researchers struggle to replicate his findings.
When Rushing to Confirm Bias, Accuracy and Sourcing Suffer
The second sentence of the introduction reads: “Today’s children are the sickest generation in American history in terms of chronic disease, and these preventable trends continue to worsen each year, posing a threat to our nation’s health, economy, and military readiness.” Yet death rates among children up to age five continue to fall, so they can’t be that sick. Could it be that more illnesses are being diagnosed today than in the past?
Sentences 3 and 4 simply repeat the message of sentences 1 and 2, while sentence 5 is nonsense: “Over the past century, U.S. GDP has grown over 30,000%.” Two of us may only be MDs, but we’re better at math than the MAHA Commission. In 1925, real GDP (2017 dollars) was about $977 billion. Real GDP (2017 dollars) in 2023 was about $22.7 trillion (according to the Bureau of Economic Analysis). The final figures for 2025 are not available yet, but 2023 serves as a useful benchmark. It’s easy to calculate that GDP has grown by 2,223 percent.
Page nine of the report claims over 40 percent of US children have a chronic health condition, citing the 2018–2019 National Survey of Children’s Health. But the survey doesn’t measure chronic conditions—it tracks current or lifelong conditions from a list that includes issues like “current anxiety problems,” “current conduct problems,” “current substance use disorder,” and “current concussion or head injury.” Many of these are temporary, and the combined prevalence reported in the survey is lower than the 40 percent figure used in the report.
Page 12 claims autism affected 1 to 4 in 10,000 children in the 1980s. But the 2007 source it cites warns that such estimates may understate prevalence due to factors like shifting criteria, increased awareness, and changing services.
On page 13, the report warns of the rise in childhood cancer rates but fails to mention that from 2001 to 2021, the cancer death rate for youth ages 0–19 years in the United States declined 24 percent, from 2.75 to 2.10 per 100,000.
The report claims on page 15 that “between 1997 and 2018, childhood food-allergy prevalence rose 88%,” based on survey data in which a parent or adult answered whether the child had a food or digestive allergy in the past year. But increased awareness over the past two decades likely led to more frequent recognition and reporting of symptoms that might have previously been overlooked or misattributed.
Even if we take the survey results at face value, the report selectively highlights only the alarming trend. It ignores the same survey’s findings that asthma attacks fell by 16.7 percent, hay fever and respiratory allergies dropped by 16 percent, and ear infections declined by 38 percent. Instead of reporting the absolute change—from 3.4 percent in 1997 to 6.4 percent in 2018—the report opts for the more dramatic “88% increase.”
Also on page 15, Footnote 43 is supposed to link the reader to an article titled “Prevalence of pediatric inflammatory bowel disease in the United States”; instead, the link directs us to a different piece titled “Model of Urgency for Liver Transplantation in Hepatocellular Carcinoma.”
Yet again on that page, the report claims celiac disease in children has increased fivefold since the 1980s but ignores that improved diagnostics and awareness likely contributed. One of its own cited studies states this clearly in the abstract.
On page 16, the commission claims that chemical exposure may be driving higher rates of chronic childhood disease, citing three sources. But none provides strong evidence to support that conclusion.
One is a literature review that clearly notes the lack of conclusive research on the effects of low-dose chemical mixtures. Another is an observational study focused on children with cancer in Nebraska, which offers no generalizable findings. The third is an editorial centered on animal and cell studies, not human children.
These are just a few inaccuracies we readily identified in the first 16 pages of the 72-page report. When a report is rushed and driven more by preconceived conclusions than by careful analysis, this is precisely the kind of quality one should expect.
The Pernicious Effects of Government Research
Perhaps the Commission’s greatest perversity is its attack on Big Pharma and Big Food. Doubtless, American farmers and pharmaceutical chemists have their flaws, but their industries are the most efficient in the world, so attacking them seems gratuitous, especially as the greatest health scandal of the post-war period was wholly government-created, namely the Food Pyramid. This pyramid is actually quite useful if it’s inverted and if people do the exact opposite of its recommendations (i.e., if they eschew carbohydrates and eat fat) but, as Nina Teicholz showed in her 2015 book Big Fat Surprise, the US’s obesity epidemic was precipitated by the federal government telling everybody to eat the unhealthiest food available, namely carbohydrate.
Dismayingly, the federal report that ushered in that dietary disaster justified its bad science by invoking a similar urgency to MAHA’s. Senator McGovern, the lead author of the Senate Select Committee on Nutrition and Human Needs’s Dietary Goals for the United States of January 14, 1977, defended its incomplete research by saying that in view of the public health emergency, “Senators do not have the luxury that the research scientist does of waiting until every last shred of evidence is in,” which is the exact opposite of the truth. Scientists are fully entitled to consider alternative theories, but senators should never impose policy on the basis of incomplete evidence. Yet in McGovern’s image, the MAHA report claims that to “better protect our children, the United States must act decisively,” even though the facts are still obscure.
Even worse, McGovern’s report distorted US nutrition science for the next three decades as government-funded research scientists worked to verify his hypothesis, and the great danger is that over the next three decades, US public health science will be equally distorted.
Alas, this is what always happens when the government becomes the principal funding source for research. “He who pays the piper calls the tune.” In his farewell address, President Eisenhower warned that we must “be alert to the equal and opposite danger that public policy could itself become the captive of a scientific-technological elite.” Researchers seeking grant money are less likely to receive it if their research challenges the prevailing narrative. As explained here, government funding corrupts science.
Robert F. Kennedy Jr.’s MAHA Commission provides an object lesson in how not to address a public health issue. If the problem is to be addressed, we should follow the example of the US government’s greatest research success, namely the Manhattan Project, and commission a leader like General Groves to assemble a group of the best scientists to write a proper and dispassionate report, free of interference from political appointees.
Public Health in a Free Society
In a free society, there is a legitimate role for government in public health, as our colleague Michael Cannon explains. It is appropriate for the government to engage in public health policy, specifically in areas where the actions of some may threaten the lives and safety of others. All too often, government-directed research and policy today focus on personal health issues, which individuals can assess and manage independently, consulting experts as needed. We know all too well that when a public health agency issues opinions on personal health matters, it effectively becomes a mandate, disclaimers aside. It is often erroneous, as with the food pyramid disaster, and suppresses dissenting viewpoints, as happened with COVID pandemic policy.
The Make America Healthy Again Commission represents the latest manifestation of the government’s mission creep from public health into personal health. Its government-funded science will almost certainly lead to a litany of health policy disasters rivalling the food pyramid disaster of the late 20th century.
Good public health policy demands humility, precision, and honesty—especially when the stakes are high. The MAHA Report offers none of these. If we want to build a healthier future for our children, we must resist the temptation of prepackaged conclusions and demand evidence-driven thinking, not ideology in disguise. When the government controls both the research agenda and the health advice, it risks turning scientific inquiry into propaganda and personal health into political theater.